Protection measures In certain cases the NPM teams established neglect in the records keeping practices at the homes. Most individual plans for social work are templates with identical content. No date of preparation and term for revision are marked on some of the plans for the long-term needs of the users, plans for departure from the institution are frequently missing. The signing of termless contracts for the use of the service is also an indication of the prevailing understanding that there should be no work with the people aimed at socialisation and reintegration, but "bringing up" within the institutional care. At the HEPMR in Batoshevo Village the NPM found that in 2011 after dispute between two users one has left the home and drowned in the nearby river. The case was not qualified as resulting from neglect by the personnel and there are no data that the latter has been investigated by the law enforcement authorities. Furthermore, during the inspection the users were freely urinating in the yard of the home and asked money from the team members while stating that if no money is given to them "they will drown in the river“. There is no dedicated register at the home reflecting the restrictive measures imposed on the users in case of aggression between the people. Immobilisation (tying up) is recorded only in the Reports book, without a note as to the beginning and end of the measure. The NPM team believes that this is a prerequisite for violation of the rights of the social service users due to the impossibility to identify specifically which user, on what grounds, how many times and for how long has been tied up. Legal status of the users The users of resident social services for elderly people are in a particularly vulnerable position since most of them are announced by the court as fully or partially disable. Their custodians / guardians are the director or another member of the staff of the specialised institution and in rare cases – relatives or next of kin, which in NPM is in contradiction with the provisions of the Family Code regulating the procedure for announcement of judicial disability. Evidence thereto are all homes inspected during the year. For example, the director of the HEPMD and HEPMR in Tvarditsa, which are under single management, is a guardian of a total of 7 people and is custodian of 105. The concerns of the NPM are very relevant as to how well one individual is capable of taking meaningful care of the interests and managing the property of so many disable elderly people in a vulnerable position. However, this position is not shared by the mayors of the municipalities, who are the guardianship and custody authority under art. 154 of the Family Code. An example of the cumulative result of the neglect of the importance of rendering high quality services to elderly people from the perspective of the location of the institution, the physical assets, management, administrative capacity, medical care and commitment of the local governance authorities is the HEPMR, Kachulka Village, Sliven Municipality. The NPM is of the opinion that the remoteness of the specialised institution, the useless physical assets, the big number of the users and the insufficient specialised personnel are 31

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